WASHINGTON (5/20/08)--The Credit Union National Association (CUNA) yesterday submitted a comment letter on proposed changes to the National Credit Union Administration’s (NCUA) questions and answers (Q&A) regarding flood insurance. The proposed changes include new questions and answers on second lien mortgages, civil money penalties, loan participations, construction loans and condominiums. The changes are intended to provide clearer guidance and clarify areas of potential misunderstanding. CUNA’s comments on the proposed changes include a clarification of the term “overall value,” which is referenced in Questions 7, 10 and 12. NCUA currently defines the term as the overall value of the property securing the designated loan minus the value of the land on which the property is located. CUNA suggested a modification of Question 31, which references flood insurance requirements for home equity loans, lines of credit, subordinate liens and other security interests in collateral. The question should be clarified to indicate that a loan application does not trigger a flood determination, CUNA said. CUNA also encouraged NCUA to ensure that the Q&A is easy for credit unions to find on the website. “Credit unions are increasingly relying on NCUA’s website for regulatory and other information that affects them, and their reliance is expected to increase,” wrote Jeffrey Bloch, CUNA senior assistant general counsel. The Q&As, originally published in 1997 by the NCUA and other federal financial institution regulators, are meant to serve as a guideline on flood insurance requirements for financial institutions, agency personnel and the public. For the full text of CUNA’s letter, use the link.